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    UnitedStates OfficeofSolidWaste EPA550-B-00-001EnvironmentalProtection and March2009Agency EmergencyResponse www.epa.gov/emergencies

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    Office

    of

    Emergency

    Management

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    This document provides guidance to owners and operators of stationary sources to determine if their

    processes are subject to regulation under section 112(r) of the Clean Air Act and 40 CFR part 68 and to

    comply with regulations. This document does not substitute for EPAs regulations, nor is it a regulation

    itself. Thus, it cannot impose legally binding requirements on EPA, states, or the regulated community,

    and may not apply to a particular situation based upon circumstances. This guidance does not represent

    final agency action, and EPA may change it in the future, as appropriate.

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    TABLE OF CONTENTS

    INTRODUCTION

    1

    Am I Covered? 1

    What Do I Have To Do? 2

    PROGRAM 1 5

    Eligibility 5

    What Must I Do For A Program 1 Process? 6

    PROGRAM 3 9

    What Must I Do For A Program 3 Process? 9

    What Are The Release Scenarios? 9

    What Do I Have To Do For The Prevention Program? 10What Do I Have To Do For The Emergency Response Program? 15

    What Do I Have To Do For My RMP? 15

    SAMPLE RMP FOR PROGRAM 1 STORAGE FACILITY 17

    SAMPLE RMP FOR PROGRAM 3 STORAGE FACILITY 23

    APPENDIX A: HOW DO I DETERMINE IF MY SEPARATE (NON-

    INTERCONNECTED) PROPANE TANKS ARE CO-LOCATED

    APPENDIX B: RELEASE CALCULATIONS

    APPENDIX C: CHECKLISTS AND OTHER DOCUMENTS

    Process Safety Information

    Propane Storage Facility Checklist

    Operating Procedure Requirements

    Maintenance Training

    Maintenance Inspection Checklist and Tests for Propane Storage Facilities

    LIST OF TABLES

    Table 1: Typical Water Capacity of Propane Tanks, Transports, and Railroad Tank Cars

    Table 2: Distance to a 1 PSI OverpressureTable 3: Distances to 1 PSI for Pipe Releases

    Table 4: Ways to Comply with Some Prevention Elements

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    TABLE OF POTENTIALLY REGULATED ENTITIES

    This table is not intended to be exhaustive, but rather provides a guide for readers

    regarding entities likely to be regulated under 40 CFR part 68. This table lists

    the types of entities that EPA is now aware could potentially be regulated by thisrule and covered by this document. Other types of entities not listed in this table

    could also be affected. To determine whether your facility is covered by the risk

    management program rules in part 68, you should carefully examine the

    applicability criteria discussed in Chapter 1 of this guidance and in 40 CFR

    68.10. If you have questions regarding the applicability of this rule to a

    particular entity, call the EPCRA/CAA Hotline at (800) 424-9346 (TDD: (800)

    553-7672).

    Category NAICS

    Codes

    SIC

    Codes

    Examples of Potentially Regulated

    Entities

    Propane

    manufacturers and

    processors

    32411

    32511

    2911

    2865

    2869

    Petroleum refineries

    Petrochemical Manufacturers

    Propane wholesalers 42271

    42272

    5171

    5172

    Bulk stations and terminals

    Other petroleum product wholesalers

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    INTRODUCTION

    This guidance is intended for propane storage facilities, such as wholesale distribution facilities and bulk

    storage terminals. This document is a revision of EPAs October 1998 guidance for propane storagefacilities. The document has been revised to reflect changes resulting from the 1999 Chemical Safety

    Information, Site Security and Fuels Regulatory Relief Act.

    If you have more than 10,000 pounds of propane stored in a single vessel or in a group of vessels (tanks,

    cylinders) that are connected or stored close together, you may need to comply with the Chemical

    Accident Prevention rule issued by the U.S. Environmental Protection Agency (EPA) under the Clean

    Air Act. The rule is codified as part 68 of Title 40 of the Code of Federal Regulations (CFR). The goal

    of this rule is to prevent accidental releases that could affect the public or the environment. If you are

    subject to part 68 for propane storage, you must be in compliance no later than January 5, 2000, or the

    date on which you first have more than a threshold quantity of a regulated substance in a process,

    whichever is later.

    If you have more than 10,000 pounds of propane, you are subject to part 68 unless one of the following

    applies to you:

    The propane is stored for use as a fuel at your facility.

    The propane is held for sale, and the facility is a retail facility. A retail facility is one at which

    more than half of the income is obtained from direct sales to end users or at which more than half

    the fuel sold, by volume, is sold through a cylinder exchange program.

    If you have more than 10,000 pounds of propane and you manufacture propane, use it as a feedstock, or

    store it in bulk for sale, other than to end users, or if your retail sales do not make up more than half of

    your income, you are subject to part 68. If you manufacture or use propane as a feedstock or store it for

    wholesale distribution and use it as a fuel, the propane used for fuel is not covered by part 68; thepropane manufactured, processed, or stored for wholesale distribution is subject to part 68 provided the

    quantity is greater than 10,000 pounds. If you use propane to fuel a covered process containing other

    regulated substances above their thresholds, the propane is not covered, but you will have to consider the

    hazards created by the propane when you conduct your process hazard analysis or hazard review.

    For most propane storage facilities, complying with this rule will be easy because most of the

    requirements are similar to those you already comply with under state or local rules based on the

    National Fire Protection Association (NFPA) standard number 58 on propane. If you are complying with

    NFPA-58 and implementing other safe engineering practices for propane, you should have little more to

    do for this rule besides filing a report with EPA.

    AM I COVERED?

    The capacity of propane tanks is usually given as water capacity (this information should be on the

    nameplate of the tank). Table 1 translates the water capacity (in gallons) into propane weight (in

    pounds). Read the tank capacity on the nameplate and check this table.

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    Table 1 assumes that tanks are filled to 88 percent of capacity, the maximum level allowable under

    NFPA-58 at 60 F. If you always keep your tanks filled to a lower level, you should adjust these numbers

    to reflect your lower inventory. If you have larger tanks, multiply the water capacity times 3.696 to

    determine pounds at 88 percent capacity.

    TABLE 1

    TYPICAL WATER CAPACITY OF PROPANE TANKS,

    TRANSPORTS AND RAILROAD TANK CARS

    Capacity in Gallons Capacity in Pounds

    Storage Tank 12,000 44,400

    Storage Tank 18,000 66,500

    Storage Tank 30,000 111,000

    Storage Tank 40,000 148,000

    Storage Tank 60,000 222,000

    Storage Tank 100,000 370,000

    Storage Tank 120,000 444,000

    Transport (Cargo Tank) 8,000 - 11,000 30,000-41,000

    Rail Car DOT Class 105J300W & 105A300W 11,000 - 34,500 41,000-128,000

    Rail Car DOT Class 112J340W & 112T340W

    114J340W & 114T340W

    114J400W & 114T400W

    26,000 - 34,500 96,000-128,000

    Bobtails (Delivery Cargo Tank) 750 - 3200 2,800-12,000

    Also, add up the amounts of propane in tanks that are connected or close together. If you have four 750

    gallon tanks, you are subject to the rule if the tanks are connected by piping, or if you store the tanks

    close enough together that they could be involved in a single accident. For example, if a fire could

    spread to all the tanks, they are considered one process, and the propane in all the tanks must be

    counted toward the 10,000-pound threshold. You should also consider whether, if one tank exploded, the

    other tanks could be affected by the shrapnel or fire. If you have several groups of propane tanks, widely

    separated, you may be considered to have multiple processes (see Appendix A for additional guidance on

    determining whether your propane tanks are separated far enough to be considered multiple processes.)

    WHAT DO I HAVE TO DO?

    The first step you should take after determining that you are covered by the rule is to decide which

    Program level you are in. EPA developed the rule with three Program levels to reflect different levels of

    risk and levels of effort needed to prevent accidents.

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    Program 1 is a minimal set of requirements for processes that have a very low risk of affecting

    the public in the event of an accident.

    Program 2is a streamlined set of requirements for processes not eligible for Program 1 or

    subject to Program 3.

    Program 3applies to processes that are not eligible for Program 1 and that are either subject to

    the Process Safety Management (PSM) Standard of the Occupational Safety and Health

    Administration (OSHA) or in certain industrial sectors (some chemical manufacturers, all

    refineries, and all pulp mills).

    This document does not provide detailed guidance on Program 3. Propane storage facilities subject to

    part 68 will generally either be eligible for Program 1 or subject to Program 3. The OSHA PSM standard

    exempts all retail facilities, using the same definition of retail facilities given above, and fuel users, but

    covers wholesalers and manufacturers that process propane. Consequently, a propane facility subject to

    part 68 will generally also be subject to the OSHA PSM standard. If you are subject to the OSHA PSM

    standard, you should also see EPAs General Guidance for Risk Management Programsor OSHAs

    Process Safety Management Guidelines for Compliance(OSHA 3133).

    If you can qualify a process for Program 1, it is in your best interests to do so, even if the process is

    already subject to OSHA PSM. For Program 1 processes, the implementing agency will enforce only the

    minimal Program 1 requirements. If you assign a process to Program 3 when it might qualify for

    Program 1, the implementing agency will enforce all of the requirements of the higher program level. If,

    however, you are already in compliance with the prevention elements of Program 3, you may want to use

    your RMP to inform the community of your prevention efforts.

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    PROGRAM 1

    ELIGIBILITY

    Some propane storage facilities will be eligible for Program 1, particularly those that are a considerable

    distance from any other business or residence. For a process to be eligible for Program 1, it must meet

    the following criteria:

    The process must not have had an accidental release of propane that led to deaths or injuries of

    people offsite or response or restoration activities at environmental receptors in the last five

    years. Environmental receptors are limited to national or state parks, forests, or monuments;

    officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness

    areas; and,

    There are no public receptors within a distance to a 1 psi overpressure from a worst-case release.

    A worst-case release is defined by the rule as the loss of the contents of the single largest vessel (or

    piping) containing the regulated substance. For propane and other flammable substances, the released

    substance is assumed to explode and generate a pressure wave that can damage people or structures. The

    rule requires you to determine the distance to a 1 psi overpressure (at 1 psi, windows will break). This

    scenario is required by the regulation, and you must adopt this scenario. Table 2 provides the worst-case

    distance to a 1 psi overpressure for propane tanks.

    TABLE 2

    DISTANCE TO A 1 PSI OVERPRESSURE

    Nominal Water Capacity

    (Gallons)

    Distance to Endpoint

    (Miles)

    500 - 1,750 0.1

    1,751 - 7,000 0.2

    7,001 - 23,000 0.3

    23,001 - 51,000 0.4

    51,001 - 90,000 0.5

    90,001 - 120,000 0.6

    If you have different quantities, RMP*Comp, a software system developed by EPA and NOAA, will

    allow you to calculate worst-case distances quickly. RMP*Comp can be downloaded from

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    www.epa.gov/emergencies/rmp. You may also use other models to develop distance estimates (see 40

    CFR 68.22 for the parameters you must use in estimating worst-case release distances). Next, you must

    determine if there are public receptors within a circle whose radius is equal to this distance. Public

    receptors include offsite residences, institutions (e.g., schools and hospitals), industrial, commercial, and

    office buildings, parks, or recreational areas inhabited or occupied by the public at any time without

    restriction by the stationary source where members of the public could be exposed to toxic concentrations,

    radiant heat, or overpressure, as a result of an accidental release. Offsite means areas beyond yourproperty boundary and "areas within the property boundary to which the public has routine and

    unrestricted access during or outside business hours." Public roads are not public receptors.

    If there are no public receptors within the distance to a 1 psi overpressure for your largest vessel and the

    process has not had an accidental release that caused any of the listed offsite impacts, your process is

    eligible for Program 1. If you have questions about whether certain areas are considered public receptors,

    call the Emergency Planning and Community Right-to-Know Act (EPCRA) hotline at (800) 424-9346(for DC area (703) 412-9810; T.D. (800) 553-7672) or check EPAs General Guidance for Risk

    Management Programs (available from the hotline or electronically at www.epa.gov/emergencies/rmp).

    WHAT MUST I DO FOR A PROGRAM 1 PROCESS?

    Because your worst-case release would not affect public receptors, you only need to do two things:

    Coordinate emergency response with your local fire department and any other local emergency

    planning and response agencies; and,

    Complete a brief Risk Management Plan (RMP), as described below

    Coordination with the fire department may consist of a discussion with them or a walk-through of your

    facility. The purpose is simply to be sure that the fire department is aware of the hazards associated with

    propane at your facility and ready to respond if an accident occurs. Also, contact your State Emergency

    Response Commission (SERC) to identify your Local Emergency Planning Committee (LEPC). You can

    get contact information for your SERC from the EPCRA hotline (noted above).

    The RMP will be filed with EPA and made available to state and local agencies and the public. EPA has

    developed a web-based submission system, called RMP*eSubmit, that will make filing a RMP or making

    changes or corrections to an existing plan easy. You can access this information at

    www.epa.gov/emergencies/rmp. EPAs previous system for electronic submission - RMP*Submit -will no longer be available on the EPA website after March 2009.

    The RMP includes registration information (basic facility information); the worst-case release scenario; a

    five-year accident history (of accidents that caused deaths, injuries, or significant property damage on

    site, known offsite deaths or injuries, offsite property or environmental damage, or evacuations or

    shelterings in place); emergency response activities; a brief executive summary; and a certification

    statement.

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    The executive summary should be a brief description of the facility, the worst-case release scenario, steps

    you take to prevent accidents (e.g., complying with state and local laws), emergency response

    information (e.g., your coordination with the fire department), and any steps you are planning to take to

    improve safety (e.g., upgrading equipment to meet newer editions of NFPA-58). The rest of the RMP is

    filling in names, addresses, and numbers, and checking appropriate boxes. You do not need to submit

    supporting documentation; you need only keep it onsite for inspection. Most propane storage facilities

    will not have any accidents to report on the five-year accident history. If you do not, you need not

    complete that section. A sample RMP for a Program 1 propane facility is attached.

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    PROGRAM 3

    If your process is not eligible for Program 1, the process is most likely in Program 3 because it is

    probably subject to the OSHA PSM standard. Most propane storage facilities that are in commercial or

    industrial areas or close to residential areas will be subject to Program 3.

    WHAT MUST I DO FOR PROGRAM 3?

    For Program 3, you must:

    Analyze both a worst-case release scenario and an alternative release scenario;

    Implement a prevention program;

    Implement an emergency response program if your employees will respond to a release; and

    File an RMP.

    WHAT ARE THE RELEASE SCENARIOS?

    Worst-Case Scenario.Part 68 defines the worst-case release scenario you must analyze. It is described

    in the previous section of this guidance (regarding Program 1). You can simply use Table 2 or

    RMP*Comp to define the distance to the 1 psi endpoint for your largest tank.

    Alternative Release Scenario. An alternative release scenario is a scenario that is more likely to

    happen. It must reach an endpoint offsite unless no such scenario exists. One of the following scenarios

    may be appropriate for you.

    Pull-Away Explosion. An alternative scenario may be a hose rupture caused by a pull-away. A

    pull-away can occur if the driver fails to remove the hoses between the storage tank and the

    transfer vehicle before moving the vehicle. In this scenario, the failure involves a 25-foot length

    of unloading hose, 4" in diameter. The active mitigation devices are assumed to work as

    designed, limiting the release to the contents of the hose. The release leads to a vapor cloud

    explosion (endpoint 1 psi). The quantity released is 69 pounds. The distance to the endpoint is

    175 feet (report as 0.03 miles).

    Piping Break. Another alternative scenario you may want to consider is a break in propane

    piping leading to a 10-minute release and explosion. The distance to the 1 psi endpoint is shown

    in Table 3.

    Appendix B includes release calculations for alternative scenarios as well as scenarios in addition to the

    two provided above.

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    TABLE 3

    DISTANCES TO 1 PSI FOR PIPE RELEASES

    Pipe Size (inches) Quantity Released (pounds) Distance to 1 psi

    0.5 4,738 0.11 18,951 0.2

    2 75,804 0.3

    You must estimate in the RMP residential populations within the circles defined by the endpoints for your

    worst-case and alternative release scenarios (i.e., the center of the circle is the point of release and the

    radius is the distance to the endpoint). You may use Census data and round to two significant digits (e.g.,

    1147 becomes 1100, and 123 becomes 120). You do not need to conduct surveys or correct Census data.

    In addition, you must report in the RMP whether certain types of public receptors (e.g., schools, hospitals)

    and environmental receptors are within the circle. You do not need to identify specific receptors; you

    simply need to check off the category.

    WHAT DO I HAVE TO DO FOR THE PREVENTION PROGRAM?

    The Program 3 prevention program is identical to the OSHA PSM Standard and has 12 elements:

    Safety information

    Process Hazard Analysis

    Operating procedures

    Training

    Mechanical Integrity (Maintenance)

    Pre-startup reviews

    Management of change

    Compliance audits Incident investigation

    Employee participation

    Hot work permit

    Contractors

    If you are complying with NFPA-58 or state or local laws based on it, following the guidelines in the

    National Propane Gas Association (NPGA) LP Gas Safety Handbook, and implementing NPGA safety

    bulletins, you are probably already doing most of what you need to do to comply with these requirements.

    The following sections provide additional information on how your current practices will help you

    comply with the EPA rule. For a more complete discussion of the requirements, see the General

    Guidance for Risk Management Programs, available at www.epa.gov/emergencies/rmp, and OSHAs

    Process Safety Management Guidelines for Compliance (OSHA 3133).

    Safety Information. You must have up-to-date information on propane and your propane equipment.

    You must have a Material Safety Data Sheet (MSDS) on propane. If you do not have one, contact your

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    supplier for a copy. You must also document your maximum intended inventory for your propane

    equipment. This will generally be the capacity of your tank or tanks; see Table 1.

    You need information on safe upper and lower temperatures, pressures, flows, and compositions. The

    following information should meet this requirement:

    Propane is a gas at normal temperatures and pressures. It is commonly liquefied by storing it in a

    closed container at pressures higher than its equilibrium vapor pressure. There is a direct

    relationship between ambient temperature and the pressure inside the storage container. As the

    ambient temperature increases, the pressure of the container increases proportionately.

    According to NFPA 58, 1998 Edition, Table B-1.2.1, commercial propane when heated to a

    temperature of 105 F will produce a pressure of 210 pounds per square inch, gauge (psig).

    NFPA 58, 1998 Edition, Table 2-2.2.2 sets the current minimum design pressure for an ASME

    tank at 250 pounds per square inch, absolute (psia). This design allows for a maximum vapor

    pressure of 215 psia at 100 F. The discharge piping for pumps and compressors is currently

    designed to 350 psi and vapor piping is designed for 250 psi according to NFPA 58, 1998

    Edition, 3-2.10.2. The minimum temperatures are determined by the steel used in the design of

    the storage tank and the piping. Liquid propane (if released at atmospheric pressure) can

    refrigerate steel pipes and tanks down to temperatures of -44 F.

    Another property of propane in its liquid form is its ability to greatly expand when heated.

    Therefore, NFPA 58, 1998 Edition sets the maximum filling capacity of large tanks in Table 4

    4.2.2(b) to avoid overfilling.

    You must maintain equipment specifications for all equipment that is part of a covered process, including

    your bulk storage tank(s), piping, pressure relief valves, hydrostatic relief valves, emergency shutoff

    valves, temperature, pressure and level gauges, valves, pumps, compressors, and hoses. Specifications

    for your bulk propane storage tank(s) are provided on the nameplate attached to the tank. If you do nothave the information, obtain it from your vendor and keep all such information on file.

    You must document the codes and standards you used to design and build your propane facility and that

    you follow to operate it. These codes will probably include the electrical and building codes that you

    must comply with under state or local laws. Your equipment vendors will be able to provide you with

    information on the codes they comply with for their products.

    The equipment specifications and lists of standards and codes will probably ensure that your process is

    designed in compliance with recognized and generally good engineering practices.

    See the EPA and OSHA guidance documents cited above for more information on the elements that must

    be documented as part of your safety information.

    Process Hazard Analysis. You are required to conduct a process hazard analysis (PHA) to identify the

    hazards associated with your equipment and propane, the possible malfunctions of equipment or human

    errors that could cause a release, the safeguards needed to control hazards or prevent malfunctions or

    errors, and any steps needed to detect or monitor releases. If you are required to comply with NFPA-58,

    your review can focus on whether you are in compliance with that standard. You may need to consider

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    external events as well as internal failures. If you are in an area subject to earthquakes, hurricanes, or

    floods, you should examine whether your system would survive these natural events without releasing

    propane. You should consider the potential impacts of lightning strikes and power failures. If your

    equipment could be hit by vehicles, you should examine the consequences of that. If you have anything

    near the process that could burn, ask yourself what would happen if the fire affected the propane tanks or

    equipment. See the EPA and OSHA guidance documents cited above for more information on analysis

    techniques and issues to be considered. Appendix C provides a checklist that you can use.

    When you complete the review, you must document the results and ensure and document that any

    problems are addressed in a timely manner.

    Operating Procedures. Written operating procedures describe the tasks you or your operators must

    perform, safe process operating parameters that must be maintained, and safety precautions for

    operations and maintenance activities. These procedures tell you or your employees how to work safely

    every day. Applicable portions of the National Propane Gas Association (NPGA) Certified Employee

    Training Program and compliance with certain NPGA Safety Bulletins can be used to meet this

    requirement. Other programs may be available that will also be acceptable. See the EPA and OSHA

    guidance documents cited above for more information on the elements that must be included in the

    procedures. A list of NPGA documents that may meet these requirements is included in Appendix C.

    Training. You must ensure that any employee presently operating a process and any employee newly

    assigned to a covered process have been trained or tested competent in the operating procedures that

    pertain to their duties. For those employees already operating a process on June 21, 1999, you may

    certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out

    the duties and responsibilities as provided in the operating procedures. You are not required to provide a

    specific amount or type of training. You should develop a training approach that works for you. The

    NPGAs Certified Employee Training Program and any training you do to meet DOT requirements may

    satisfy this requirement. You must provide refresher training. You must determine the frequency ofrefresher training in consultation with any affected employees, but you must provide refresher training at

    least once every three years. Training must be documented.

    Maintenance. You must prepare and implement procedures to maintain the on-going mechanical

    integrity of your propane equipment. You may use procedures or instructions provided by equipment

    vendors or procedures in Federal or state regulations or industry codes as the basis for maintenance

    procedures. You must also train maintenance workers in these procedures (if a contractor maintains your

    equipment, the contractors employees should be trained as well). NPGAs Certified Employee Training

    Program covers many of the maintenance procedures for your propane equipment.

    You must establish a schedule for inspecting and testing equipment associated with your propane storage

    facility. You may obtain recommendations from manufacturers, vendors, or trade associations. Youshould, however, use your own experience as a basis for examining any schedules you obtain from

    others. Many things may affect whether a schedule is appropriate. The manufacturer may assume a

    constant rate of use. If your actual rate of use (e.g., the amount of propane pumped per hour) varies

    considerably, the variations may cause additional wear on the equipment. Extreme weather conditions

    may also increase wear on equipment.

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    If you have workers that use your propane facility, talk with them as you prepare or adopt these

    procedures and schedules. If their experience indicates that equipment fails more frequently than the

    manufacturer expects, you should adjust the inspection schedule to reflect that experience.

    See the EPA and OSHA guidance documents cited above for more information on these requirements.

    A list of NPGA training that applies to maintenance procedures and a maintenance inspection checklist

    are included in Appendix C.

    Management of Change. You must prepare and implement procedures to manage changes, except

    replacements in kind. The purpose of this requirement is to ensure that changes you make do not create

    any new hazards and that your employees and contractors are informed of the changes and trained in any

    new procedures that are needed prior to start-up. See the EPA and OSHA guidance documents cited

    above for more information on these requirements.

    Pre-Startup Review. Whenever you install a new covered process or modify an existing one, you must

    perform a pre-startup review to ensure that the equipment is in accordance with the design specifications,that all procedures related to the equipment are up-to-date, and that employees have been trained in the

    operation of the new or modified process. See the EPA and OSHA guidance documents cited above for

    more information on these requirements.

    Compliance Audits. At least every three years, you must certify that you have evaluated compliance

    with EPAs requirements for the prevention program for each covered process. At least one person who

    conducts the audit must be knowledgeable about the process. You must develop a report of the audits

    findings, determine and document an appropriate response to each finding, and document that you have

    corrected all deficiencies. You must retain compliance audit reports for five years.

    Incident Investigation. You must investigate each incident that resulted in, or could have resulted in, a

    catastrophic release of propane. A catastrophic release is one that presents an imminent andsubstantial endangerment to public health and the environment. You must start the investigation no later

    than 48 hours after the accident. You must create a report on the accident that includes, at least, the date

    of the accident and the date the investigation began, a description of the accident, the factors that

    contributed to the accident, and any recommendations that resulted from the investigation. You must

    address the recommendations and share the findings with any employees whose jobs are affected by the

    findings. Investigation reports must be retained for five years.

    The NPGA LP-Gas Safety Handbook, and NPGA bulletin #202-93 After Accident Procedure may

    help you comply with this requirement.

    Employee Participation. You must develop a written plan to implement the requirements for employee

    participation. See the OSHA guidance document cited above for more information on this requirement.

    Hot Work Permit. You must issue hot work permits for hot work conducted near your covered process.

    See the OSHA guidance document cited above for more information on this requirement.

    Contractors. If you use contractors to perform maintenance, renovation, or specialty work on or near a

    covered process, you must implement a program to ensure that your contractors are qualified to perform

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    the work and are informed of the potential hazards. See the OSHA guidance document cited above for

    more information on these requirements.

    Table 4 summarizes the ways that propane facilities can comply with some of these requirements.

    TABLE 4

    WAYS TO COMPLY WITH SOME PREVENTION ELEMENTS

    Program 3 Prevention Element How a Propane Facility Can Meet This Requirement

    Safety Information - Maintain Material Safety Data Sheets on propane

    - Use the information provided in this guidance

    - Document NFPA-58 information

    - Maintain propane equipment vendor-supplied information

    - Maintain records on electrical and building codes followed

    Hazard Review - Use checklist in Appendix C

    - Review compliance with NFPA-58

    Operating Procedures - Implement NPGA Certified Employee Training Program

    - Comply with NFPA-58

    - Comply with NPGA safety bulletins

    - Use written operating procedures for propane systems

    Training - Implement NPGA Certified Employee Training Program.

    - Document training done to meet DOT requirements

    - Document training done to comply with NFPA-58

    - Comply with NPGA Safety Bulletins

    - Provide refresher training at least every three years

    Maintenance - Implement NPGA Certified Employee Training Program

    - Use checklist in Appendix C

    - Establish a maintenance and testing schedule

    - Document inspections and maintenance done by equipment

    vendors

    Compliance Audits - Conduct and document a compliance audit every three years;

    respond to each finding, and document that you have corrected

    any deficiencies.

    Incident Investigation - Implement practices in NPGAs LP-Gas Safety Handbook

    - Implement NPGA bulletin #202-93 After Accident Procedure

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    WHAT DO I HAVE TO DO FOR THE EMERGENCY RESPONSE PROGRAM?

    If you have at least one Program 3 process at your facility, you may be required to implement an

    emergency response program, consisting of an emergency response plan, emergency response equipment

    procedures, employee training, and procedures to ensure the program is up-to-date. This requirement

    applies if your employees will respond to some releases involving propane. The emergency response

    section of EPA's rule allows you to decide first whether the employees will respond to an accidental

    release of propane and then what involvement the employees will have in the event of a release of

    propane. If you choose not to have employees respond, then you must coordinate response actions with

    the local fire department and have in place appropriate mechanisms to notify emergency responders when

    there is a need for a response.

    Some propane storage facilities will rely on local responders to handle any accident. If you plan to have

    your employees respond to a propane release, you should consult EPAs General Guidance for Risk

    Management Programsto determine what you need to do to develop and implement an emergency

    response program.

    WHAT DO I HAVE TO DO FOR MY RMP?

    The RMP for a Program 3 process will include the same sections covered in the Program 1 process, plus

    a report on the alternative release scenario and the report on the prevention program. Except for the

    executive summary, the RMP consists of names, numbers, and check-off boxes. If you have more than

    one process, you still file only one RMP. If you have multiple Program 3 processes, but they all contain

    propane, you report only one worst-case scenario and one alternative scenario to cover all of them. (If

    you have multiple Program 1 processes, you must report a worst-case scenario for each Program 1

    process to establish that the process is eligible for Program 1.)

    If you have one Program 3 process, your RMP will include:

    The executive summary (covering the alternative release scenario as well as worst-case)

    Registration data

    Worst-case and alternative release data

    Five-year accident history (only if youve had any accidents to report)

    Prevention program data

    Emergency response data

    The certification

    A sample RMP and certification statement for a Program 3 propane facility is attached.

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    SAMPLE RMP for PROGRAM 1 PROPANE STORAGE FACILITY(This sample RMP is for a fictitious facility named, Smith Gas Company Terminal.

    Any resemblance to any actual facility is accidental).

    CERTIFICATION STATEMENT

    Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental releasescenario for the following processes is less than the distance to the nearest public receptor:

    Wholesale LPG facility

    Within the past five years, the process has had no accidental release that caused offsite impacts provided in the riskmanagement program rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impactsfrom accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process,entry within the distance to the specified endpoint may pose a danger to public emergency responders. Therefore,

    public emergency responders should not enter this area except as arranged with the emergency contact indicated in

    the RMP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed afterreasonable inquiry, the information submitted is true, accurate, and complete.

    William R. Smith William R. SmithSignature Print Name

    Company Owner 6/21/99Title Date

    EXECUTIVE SUMMARY

    The accidental release prevention and emergency response policies at your facility: This facility complies withNFPA-58 requirements for LP-Gas storage, and it is our policy to adhere to all applicable federal, state, and locallaws. If an emergency were to occur, it is our policy to notify the Garvin County Fire Department and request thatthey respond to the emergency.

    A description of your facility and the regulated substances handled. This facility wholesales LPG, supplyingretail outlets, primarily gas stations and cylinder filling operations at cooperatives. The facility consists of a single18,000-gallon tank, which we fill to between 85% and 88% capacity.

    The worst-case release scenario. Our worst-case scenario is failure of the 18,000-gallon storage tank when filledto the greatest amount allowed (88% at 60F), resulting in a vapor cloud explosion. Since this facility is located in arelatively remote, unoccupied area, the worst-case scenario would not affect anyone beyond our property.

    The general accidental release prevention program and chemical-specific prevention steps. This facilitycomplies with EPAs accident prevention rule and all applicable state and local codes and regulations. The propane

    system is designed, installed, and maintained in accordance with NFPA-58 and state law.

    Five-year accident history. We have never had an accident involving propane that caused deaths, injuries, propertyor environmental damage, evacuations, or shelterings in place.

    The emergency response program. In the event of an emergency involving our propane system, it is our policy tonotify the Garvin County Fire Department and request that they respond to the emergency. We have discussed this

    policy with the fire department; members of the fire department have inspected our propane system.

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    b. Title: Company owner

    1.8. Emergency Contact

    a. Name:William R. Smith

    b. Title: Company owner

    c. Phone: (555) 555-5555

    d. 24-hour phone: (555) 555-1111 e. Ext. or PIN:

    1.9. Other Points of Contact (Optional)

    a. Facility or parent company e-mail address:

    b. Facility public contact phone: (555) 555-5555

    c. Facility or parent company www homepage address:

    1.10. LEPC (Optional): Garvin County LEPC

    1.11. Number of full-time employees (FTEs) On Site: 1

    1.12. Covered by (select all that apply)

    a. OSHA PSM: Yes

    b. EPCRA section 302:

    c. CAA Title V Air Operating Permit ID:

    1.13. OSHA Star or Merit Ranking: No

    1.14. Last Safety Inspection Date: 12/07/97

    1.15. Last Safety Inspection Performed by (select one) Fire department

    1.16. Will this RMP involve Predictive Filing? No

    1.17. Process Specific Information. For each covered process fill in the following chart. Use a separate sheet foreach process.

    Process Number: 1(optional to help youtrack)

    Process Description: Storage tank

    (optional to help youtrack)

    a. Program Level: 1

    b. NAICS Code(s): 42272

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    c. Chemical c.1. Name:

    Propane

    c.2. CAS Number:

    74-98-6

    c.3. Quantity (lbs.):

    67,000

    4. FLAMMABLES: WORST CASE

    4.1. Chemical Name

    4.2. Results based on (select one)

    Propane

    c. EPAs RMP Guidance for Propane Storage FacilitiesReference Tables or Equations

    4.3. Scenario: Vapor Cloud Explosion

    4.4. Quantity released (lbs.) 67,000 pounds

    4.5. Endpoint Used: 1 psi

    4.6. Distance to endpoint (miles) 0.30 miles

    4.7. Residential population within distance to endpoint 0

    4.8. Public receptors within distance to endpoint (select all that apply)

    a. Schools d. Prisons /Correctional facilities

    b. Residences e. Recreation areas

    c. Hospitals f. Commercial/industrial areas

    4.9. Environmental receptors within distance to endpoint (select all that apply)

    a. National or state parks, forests, or monuments

    b. Officially designated wildlife sanctuaries, preserves, or refuges

    c. Federal wilderness area

    4.10. Passive mitigation considered (select all that apply)

    a. Dikes

    b. Fire walls

    c. Blast walls

    d. Enclosures

    e. Other (specify)

    4.11. Graphics file name (Optional)

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    9. EMERGENCY RESPONSE

    9.1. Emergency response (ER) plan

    a. Is facility included in the written community emergency response plan? No

    b. Does facility have its own written emergency response plan? No

    9.2. Does facility ER plan include specific actions to be taken in response to accidental releases of regulated

    substance(s)?

    9.3. Does facility ER plan include procedures for informing public and local agencies responding to accidental

    release?

    9.4. Does facility ER plan include information on emergency health care?

    9.5. Date of most recent review/update of facility ER plan

    9.6. Date of most recent emergency response training for facilitys employees

    9.7. Local agency with which the facility ER plan or response activities are coordinated

    a. Name of agency Garvin County Fire Department

    b. Phone number (555) 555-1000

    9.8. Subject to (select all that apply)

    9.8.a. OSHA 1910.38

    9.8.b. OSHA 1910.120

    9.8.c. Clean Water Act/SPCC

    9.8.d. RCRA

    9.8.e. OPA-90

    9.8.f. State EPCRA rules/law

    9.8.g. Other (specify)

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    SAMPLE RMP for PROGRAM 3 PROPANE STORAGE FACILITY

    (This sample RMP is for a fictitious facility named Maryland LPG.Any resemblance to any actual facility is accidental).

    CERTIFICATION STATEMENT

    To the best of the undersigneds knowledge, information, and belief formed after reasonable inquiry, theinformation submitted is true, accurate, and complete.

    Mary L. JonesSignature

    Mary L. JonesPrint Name

    Company OwnerTitle

    6/21/99Date

    EXECUTIVE SUMMARY

    The accidental release prevention and emergency response policies at your facility: This facility complies withNFPA-58 requirements for LP-Gas storage, and it is our policy to adhere to all applicable federal, state, andlocal laws. If an emergency were to occur, it is our policy to notify the Howard County Fire Department andrequest that they respond to the emergency. We also maintain a fire brigade on site to handle small emergencies.

    A description of your facility and the regulated substances handled. This facility is a bulk terminal storingLPG for resale to retail propane outlets. The facility consists of four 30,000-gallon tanks and two 120,000gallon tanks.

    The worst-case and alternative release scenarios. Our worst-case scenario is failure of one 120,000-gallonstorage tank when filled to the greatest amount allowed (88% at 60F), resulting in a vapor cloud explosion. Theresulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint.Our alternative release scenario is a break in a 0.5-inch diameter pipe, leading to a 10-minute release andexplosion. The resulting distance to the endpoint extends offsite, and public receptors are within the distance tothe endpoint.

    The general accidental release prevention program and chemical-specific prevention steps. This facilitycomplies with EPAs accident prevention rule, the OSHA PSM standard, and all applicable state and local codesand regulations. The propane system is designed, installed, and maintained in accordance with NFPA-58 andstate law.

    Five-year accident history. We have never had an accident involving propane that caused deaths, injuries,property or environmental damage, evacuations, or shelterings in place.

    The emergency response program. In the event of an emergency involving our propane system, it is our policyto notify the Howard County Fire Department and request that they help respond to the emergency. We also

    have a trained fire brigade. We have coordinated our response plans with the fire department; members of thefire department have inspected our propane system and conducted a joint exercise with us.

    Planned changes to improve safety. None.

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    1. REGISTRATION

    1.1 Source Identification

    a. Facility Name: Maryland LPG

    b. Parent Company #1 Name: N/A

    c. Parent Company #2 Name:

    1.2. RMP Facility Identifier: [EPA will assign]

    1.3. EPA Identifier:

    1.4. Dun and Bradstreet Numbers (DUNS) N/A

    a. Facility DUNS:

    b. Parent Company #1 DUNS:

    c. Parent Company #2 DUNS:

    1.5 Facility Location Address

    a. Street 238 Main Street

    b. Street - Line 2:

    c. City: Odenton d. State: MD e. Zip Code: 21873 f. County: Howard

    g. Facility Latitude (degrees, minutes, and seconds): 39 11 15

    h. Facility Longitude (degrees, minutes, and seconds): -076 50 10

    i. Method for determining Lat/Long : I1 (interpolation, map)

    j. Description of location identified by Lat/Long : AB Administrative Building

    1.6 Owner/Operator

    a. Name: Mary L. Jones

    b. Phone: (410) 777-1234

    Mailing Address:

    c. Street 1: 238 Main St.

    e. City: Odenton f. State: MD g. Zip: 21873

    1.7. Name and title of person responsible for RMP (part 68) implementation

    a. Mary L. Jones

    b. Company Owner

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    1.8. Emergency Contact

    a. Name: Mary L. Jones

    b. Title: Company owner

    c. Phone: (410) 777-1234

    d. 24-hour phone: (410) 777-4321 e. Ext. or PIN:

    1.9. Other Points of Contact (Optional)

    a. Facility or parent company e-mail address:

    b. Facility public contact phone: (410) 777-1234

    c. Facility or parent company www homepage address:

    1.10. LEPC (Optional): Howard County LEPC

    1.11. Number of full-time employees (FTEs) On Site: 6

    1.12. Covered by (select all that apply)

    a. OSHA PSM: Yes

    b. EPCRA section 302:

    c. CAA Title V Air Operating Permit ID:

    1.13. OSHA Star or Merit Ranking: No

    1.14. Last Safety Inspection Date: 10/19/98

    1.15. Last Safety Inspection Performed by (select one) Fire department

    1.16. Will this RMP involve Predictive Filing? No

    1.17. Process Specific Information. For each covered process fill in the following chart. Use a separate sheet foreach process.

    Process Number: 1(optional to help youtrack)

    Process Description: Storage Tanks

    (optional to help you

    track)

    a. Program Level: 3

    b. NAICS Code(s): 42271 Petroleum Bulk Terminal

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    c. Chemical c.1. Name:

    Propane

    c.2. CAS Number:

    74-98-6

    c.3. Quantity (lbs.):

    1,331,000

    4. FLAMMABLES: WORST CASE

    4.1. Chemical Name

    4.2. Results based on (select one)

    Propane

    c. EPAs RMP Guidance for Propane Storage FacilitiesReference Tables or Equations

    4.3. Scenario: Vapor Cloud Explosion

    4.4. Quantity released (lbs.) 120,000 pounds

    4.5. Endpoint Used: 1 psi

    4.6. Distance to endpoint (miles) 0.60 miles

    4.7. Residential population within distance to endpoint 200

    4.8. Public receptors within distance to endpoint (select all that apply)

    a. Schools d. Prisons /Correctional facilities

    b. Residences

    e. Recreation areas

    c. Hospitals

    f. Commercial/industrial areas

    4.9. Environmental receptors within distance to endpoint (select all that apply)

    a. National or state parks, forests, or monuments

    b. Officially designated wildlife sanctuaries, preserves, or refuges

    c. Federal wilderness area

    4.10. Passive mitigation considered (select all that apply)

    a. Dikes

    b. Fire walls

    c. Blast walls

    d. Enclosures

    e. Other (specify)

    4.11. Graphics file name (Optional)

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    5.12. Graphics file name (Optional)

    7. PREVENTION PROGRAM - PROGRAM 3

    For each process or process unit:

    7.1. NAICS Code for process: 42271

    Propane7.2. Chemical name(s):

    7.3. Safety information

    Date of most recent review/revision of safety information 02/04/97

    7.4. Hazard review

    a.1 Date of completion of most recent PHA/update 02/04/98

    a.2 Technique used Checklist

    b. Expected date of completion of any changes resulting from the PHA 02/04/98

    c. Major hazards identified (select at least one)

    Toxic release Overpressurization Earthquake

    Fire

    Corrosion Floods

    Explosion

    Overfilling

    Tornado

    Runaway reaction Contamination Hurricanes

    Polymerization Equipment Failure Other

    Loss of cooling, heating, electricity, instrument air

    7.4.d. Process controls in use (select at least one)

    Vents Emergency air supply

    Relief valves

    Emergency power

    Check valves Backup pump

    Scrubbers Grounding equipment

    Flares Inhibitor addition

    Manual shutoffs

    Rupture disks

    Automatic shutoffs

    Excess flow device

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    7.7. Maintenance

    a. Date of most recent review/revision of maintenance procedures 04/01/97

    b. Date of most recent equipment inspection/test 10/19/98

    c. What equipment inspected/tested Propane tanks, valves, and piping

    7.8 Management of Change

    a.

    Date of the most recent change that triggered management of change procedure:

    b. Date of the most recent review or revision of management of change procedures: 6/14/98

    7.9 Pre-Startup Review

    The date of the most recent pre-startup review:

    7.10. Compliance audits

    a. Date of most recent compliance audit

    b. Expected date of completion of any changes resulting from the compliance audit

    7.11. Incident investigation:

    a. Date of most recent incident investigation

    b. Expected date of completion of any changes resulting from the investigation

    7.12 Employee participation plan

    Date of the most recent review or revision of the employee participation plan: 4/16/99

    7.12 Hot work permit procedures

    Date of the most recent review or revision of the hot work permit procedures: 24/12/97

    7.13 Contractor safety procedures

    a. Date of the most recent review or revision of the contractor safety procedures: 4/16/99

    b. The date of the most recent review or revision of contractor safety performance: 4/16/99

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    A-2

    To determine whether adjacent, non-interconnected propane tanks constitute a single process,

    measure the linear distance between the tanks and compare it to the estimated separation distance in

    Table A-1 for tanks of that size and with that degree of confinement. Tanks that are separated by less

    than the estimated separation distance in Table A-1 should generally be considered a single processand their quantities added together to determine if the process exceeds the RMP threshold of 10,000

    pounds. Individual tanks of propane which are separated by at least the estimated separation distance

    in Table A-1 for tanks of that size and with that degree of confinement may generally be considered as

    separate processes and thus not subject to the RMP regulation.

    The distances provided in the Table above should be treated as estimates. Other methods of

    determining separation distances may provide more accurate estimates and you are free to use other

    reasonable methods if you choose. Also, the separation distances provided here should be considered

    in relation to any unique circumstances at your site, such as topography, the presence of structures and

    obstacles, the presence of blast-mitigation features, and other site-specific factors. For example, if

    engineered blast-barriers are located between tanks, or if your tanks are underground, smaller

    separation distances may be appropriate3. On the other hand, topographical features, such as adepression between two tanks where heavier-than-air propane vapor might collect, may warrant the

    use of larger separation distances. Additionally, you should evaluate whether there are potential

    events other than vapor cloud explosions that could reasonably be expected to cause multiple tanks to

    fail, even at distances larger than those in Table A-1. EPA believes that for most properly designed

    outdoor propane installations, such events are extremely unlikely, and that separating tanks by at least

    the appropriate distance in Table A-1 is sufficient to establish separate processes. However, you

    should evaluate your own circumstances and maintain documentation to support your determination.

    Some readers of this guidance may conclude that it will be easier to re-locate one or more of their

    propane tanks to conform to the distances provided above rather than taking the steps necessary to

    comply with the regulation. This is certainly permitted, and in some cases may be an appropriate risk-

    reduction measure. However, when taking such actions, you should be careful to maintain sufficientseparation distances between your propane tanks and nearby buildings, roads, and public receptors.

    EPA recommends consulting NFPA-58 or other applicable codes or standards to identify such

    distances.

    3 NFPA-58 generally recommends against installing fire walls, fences, earth or concrete barriers, and other similar

    structures around or over non-refrigerated LP-gas containers. There are some exceptions. For example, the standard permits

    such structures to partially enclose LP-gas containers, if the structure is designed in accordance with a sound fire protection

    analysis.

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    APPENDIX B

    RELEASE CALCULATIONS

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    APPENDIX B - RELEASE CALCULATIONS

    The endpoints that can be considered for the alternative release scenario are explosion damage,

    radiant heat effect and lower flammability limit vapor concentration. Review these potential

    alternative scenarios and pick one or more that best describes a scenario that is more likely to occur

    than the worst-case scenario and that has an endpoint which is beyond your facility boundary. The

    following are possible alternative release scenarios that use a vapor cloud explosion and an

    overpressure of 1 psi.

    PULL-AWAY: (ACTIVE MITIGATION DEVICES PERFORM AS DESIGNED)

    An alternative scenario for a propane storage facility may be a hose rupture caused by a pull-away. A

    pull-away can occur if the driver fails to remove the hoses between the storage tank and the transfer

    vehicle (bobtail or transport) before moving the vehicle. In this case, the analysis considers the failure

    of a 25 foot length of unloading hose, 4" in diameter. The active mitigation devices are assumed to

    work as designed, limiting the release to the contents of the hose.

    Volume of hose = cross sectional area of hose x length of hose

    Volume of hose = (4 in / 2)2 1 ft2/ 144 in2 25 ft = 2.182 ft3

    Wf= 2.182 ft3 .504 62.37 pounds/ft3 = 68.59 pounds of propane

    There are three methods described in EPA's OCA that you can use to determine the distance to the

    endpoint for an alternative scenario. Two of those methods are used here as an example.

    PULL-AWAY EXPLOSION

    You can use equation C-1 from EPA's OCA to calculate the distance exposed to greater than 1 psi

    overpressure. This method results in a distance to endpoint of 175 feet and the endpoint is 1 psioverpressure.

    D = 17 ( 0.1 Wf HCf/ HCTNT)a

    Where,

    Wf is the weight of propane in kilograms in the vapor cloud,

    Hcf is the heat of combustion of propane from Appendix C of EPA's OCA,

    HcTNT is the heat of combustion of TNT from Appendix C of EPA's OCA, and

    D is the distance in meters from the explosion where overpressure exceeds 1 psi.

    D = 17 (.1 Wf 46333/4680)a= 17 (.1 68.6/2.2046 46333/4680)a= 53.29 meters =

    D = 174.8 feet

    If you use this scenario as your alternative release scenario, the distance to endpoint is 175 feet and

    the endpoint used is 1 psi overpressure.

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    B-2

    PROCESS PIPING BREAKS

    Liquid propane pipe failures: ", 1", 2", 3", 4" and 6". (Causes: liquid expansion [failure of

    hydrostatic valves], a pull-away [failure of breakaway devices4

    ], collision, corrosion.) For long pipes,where the length to diameter ratio is significantly greater than one, flashing (i.e., conversion of

    gaseous propane to liquid) in the discharge pipe results in a two-phase release. You can estimate the

    amount released from a line shear using the following equation:

    )0.5]QR = 0.0853 HA F L / [Vgl (T Cp

    Where: QR is the release rate in pounds per minute.

    HA is the cross-sectional area of the pipe in square inches.

    F is the frictional factor, which is 0.85 for pipe with a length to diameter ratio of 50.

    L is the heat of vaporization, which is 426,000 joules per kilogram for propane.

    Vgl is the specific volume of gas minus liquid in m3/kg, which is 0.056 for propane.

    T is the temperature in Kelvins (assumed to be 298).Cp is the heat capacity, which is 2,400 joules/kilogram/Kelvin for propane.

    0.0853 is a units conversion factor.

    QR can be calculated using the values in the table below for HA. Now Q (the release quantity) can be

    calculated for a 10-minute release, and D (the distance to the endpoint in feet) can be calculated using

    equation C-1 from EPAs OCA. Note that Q cannot be larger than the amount of propane contained

    in your storage tank (this should be considered especially for 6" pipes).

    For a 1" pipe:

    QR = 512.5 pounds per minute

    Q = QR 10 minutes = 5,125 total pounds released (Q = Wf)

    D = 17 ( 0.1 Wf HCf/ HCTNT)a= 17 (0.1 5,125 / 2.2046 46333 / 4680)a= 224

    D = 224 meters = 735 feet = 0.1 mile

    If you use this scenario as your alternative release scenario, the distance to endpoint is 735 feet (or

    about 0.1 mile) and the endpoint used is 1 psi overpressure.

    4 See NFPA 58, 1998 Edition, Section 3-9.4.2. A breakaway device is used when dispensing LPG. It is designed so that the

    breakaway device fails (instead of the piping or hose) allowing other safety devices to retain the fuel and limit the spill. Failure of the breakaway

    device means that the breakage occurs somewhere else rather than at the breakaway device during a pull away, thus negating the effectiveness

    of some or all of the other safety devices.

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    B-3

    TABLE B-1

    POTENTIAL DISTANCES TO ENDPOINT FOR PIPE RELEASES

    (for 1 psi Overpressure)

    Pipe Size (inches) HA (inches2) QR

    (pounds/minute)

    Q Total Amount

    Released after 10

    minutes (pounds)

    D (Miles)

    0.50 0.20 128 1,281 0.1

    1 0.79 512 5,125 0.1

    2 3.14 2,050 20,499 0.2

    3 7.07 4,612 46,122 0.3

    4 12.57 8,199 81,995 0.4

    6 28.27 18,449 184,488 0.5

    OVERFILL STORAGE TANK - RELIEF VALVE LIFTS

    A safety relief valve lifts (causes: overpressure or overfilling [failure of your level indicator and

    administrative procedures]).

    A four-valve multiport relief valve has a flow capacity of 27,750 SCFM/Air at 300 psi with three of

    the four valves lifting. Estimate the amount of propane discharged from one port over 5 minutes and

    the distance to endpoint if the vapor cloud finds a source of ignition and explodes. The density of air

    is 12.39 ft3/lb and the density of propane is 8.66 ft3/lb. To convert SCFM (air)to SCFM (propane)multiply

    by 0.808.

    The release rate from one port is 27,950 SCFM (air)/ 3 = 9,250 SCFM (air)

    Q(propane)= Q(air) 0.808 / 8.66 ft3/lb = 863 lbs/min 5 min = 4,315lbs = 1957.4 kg

    D = 17 (0.10 1957.4 46,333/4680)a= 211.9 meters 3.281 ft/meter = 695.2ft / 5280ft/mile =0.13 miles.

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    TABLE B-2

    RELIEF VALVE DISCHARGES (FOR 1 PSI OVERPRESSURE)

    Relief Valve Size(inches) CapacitySCFM of

    Air

    Release Rate(lbs/min)

    Propane

    Duration(min) AmountReleased

    (lbs)

    Distance toEndpoint

    (Miles)

    Multiport 2" 9,250 863 5 4,315 0.1

    Dual Port 1" 5,250 490 5 2,449 0.08

    2" 10,390 969 5 4,847 0.1

    1" 6,080 567 5 2,836 0.1

    1" 5,280 492 5 2,463 0.1

    1 " 3,340 312 5 1,558 0.09

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    APPENDIX C

    CHECKLISTS AND OTHER DOCUMENTS

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    PROCESS SAFETY INFORMATION

    Process Safety Information Worksheet: Propane Storage

    Item Description

    MSDS Propane

    Maximum Intended Inventory

    Nominal Water Capacity of Largest

    Tank

    Temperature Upper:

    Lower:

    Pressure Upper:

    Lower:

    Flow Rate Loading:Unloading:

    Vapor Piping

    Liquid Piping

    Safety Relief Valves

    RV1

    RV2

    RV3

    RV4

    Internal Valve

    Excess Flow Valve

    EFV1

    EFV2

    EFV3

    EFV4

    Emergency Shutoff Valve

    ESV1

    ESV2

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    Item Description

    Hydrostatic Relief Valve

    HSV1

    HSV2

    HSV3

    HSV4

    HSV5

    HSV6

    Pump 1

    Pump 2

    Compressor 1

    Compressor 2

    Vaporizer Type: Sz. Flow:

    Strainer

    Check valves

    Sightflow Indicator

    Tank Level Indicator

    Tank Temperature Indicator

    Tank Pressure Indicators

    Other Temperature Indicators

    Other Pressure Indicators

    Design Codes

    State or Local Codes

    Piping Design

    Tank Design ASME NB# State ID#

    Vaporizer Design ASME NB# State ID#

    Date of Most Recent Revision Revised By:

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    PROPANE STORAGE FACILITY CHECKLIST5,6

    Answer the questions below by indicating "Yes", "No" or "N/A" (for not applicable). "No" responses

    require further comment and a projected completion date for correcting the deficiency.

    Siting Yes/No/NA Comments

    1. Does the arrangement of your fixed storage tanks conform

    with the minimum distances allowed in Table 3-2.2.2 of

    NFPA 58, 1998 Edition?

    2. Are your fixed storage tanks separated from any oxygen or

    hydrogen storage by the minimum distances given in Table

    3-2.2.7(f) of NFPA 58, 1998 Edition?

    3. Are your transfer points separated from the exposure

    points by the minimum distances given in Table 3-2.3.3 of

    NFPA 58, 1998 Edition?

    Piping, Equipment & Container Appurtenances Yes/No/NA Comments

    1. Is your storage facility designed according to ASME

    code for pressure vessels?

    Fixed Storage Tanks ASME?

    Vaporizers ASME?

    2. Is the pressure rating of your storage tanks appropriate forthe product in service?

    Storage Tanks?

    Vaporizers?

    3. Is the stored product properly identified?

    4. On installations with multiple tanks, are the elevations of

    your storage tanks arranged to prevent unintentional

    overfilling of the lowest container?

    5 Completing the Propane Storage Facility Hazard Review Checklist does not guarantee that your facility is in complete compliance

    with NFPA 58, 1998 Edition.

    6 The Propane Storage Facility Hazard Review Checklist is based on NFPA 58, 1998 Edition. Over the years, various changes

    in NFPA 58 have been made to reduce the probability of a propane release. You should carefully review any change to NFPA 58 since your

    facility was constructed and consider appropriate changes to ensure the safety of your facility. Document the actions that you take. You should

    be ready to explain any differences between the version of NFPA 58 that you used to construct your facility and the current version.

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    Piping, Equipment & Container Appurtenances Yes/No/NA Comments

    5. On installations with stairways or ladders, are they well

    anchored, supported and of slip proof construction?

    6. On installations with stairways or ladders, are railings

    provided and in good condition?

    7. On installations with stairways or ladders, are catwalks

    provided so personnel need not walk on any portion of

    the container?

    8. Is your piping designed according to NFPA 58, 1998

    Edition, Section 3-2.10?

    Are your pump and compressor discharge and liquid

    transfer lines suitable for a working pressure of 350 psi?

    Is your vapor piping suitable for a working pressure of

    250 psi?

    On installations with vaporizers, are your vaporizers

    designed according to 2-5.4.2 or 2-5.4.3 or 2-5.4.4 and

    2-5.4.5 or 2-5.4.6 or 2-5.4.7 of NFPA 58, 1998

    Edition?

    9. Is the relief capacity of your pressure relief devices:

    For fixed storage tanks, designed according to Sections 2

    3.2 and 3-2.5 or 3-2.6 of NFPA 58, 1998 Edition?

    On installation with vaporizers, are your vaporizers

    designed according to 2-5.4.5 or 2-5.4.6 or 2-5.4.7 of

    NFPA 58, 1998 Edition?

    10. Is the capacity of your pressure relief devices designed

    according to 2-3.2 and 3-2.5 or 3-2.6 of NFPA 58, 1998

    Edition?

    Have your relief devices been tested or replaced every ten

    years according to the good practice recommended by

    Section E-2.3.2 of NFPA 58, 1998 Edition?

    11. Do you have appropriate level gauges, temperature

    indicators, and pressure gauges installed on your fixed

    ASME storage tanks as specified in 2-3.3.2(b), 2-3.3.3,

    2.3.4, 2.3.5 of NFPA 58, 1998 Edition?

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    Piping, Equipment & Container Appurtenances Yes/No/NA Comments

    12. Do you have the appropriate hydrostatic relief valves

    installed between every section of liquid piping which

    can be blocked by manual or automatic valves accordingto 2-4.7 and 3-2.11 of NFPA 58, 1998 Edition?

    13. Do you have the appropriate corrosion protection

    required by 3-2.14 of NFPA 58, 1998 Edition?

    14. On installations with pumps, are they installed according

    to 3-2.15.1 of NFPA 58, 1998 Edition?

    On installations with automatic bypass valves, are they

    installed on the discharge of your pump according to

    3.2.15(b)1 and 2-5.2 of NFPA 58, 1998 Edition?

    15. On installations with compressors, are they installed

    according to 2-5.3 and 3-2.15.2 of NFPA 58, 1998

    Edition?

    On installations with compressors, is there either an

    integral means of preventing liquid from entering the

    compressor or a liquid suction protection trap according

    to 3-2.15.2(b) of NFPA 58, 1998 Edition?

    16. Do your compressor and pump motors conform with 2

    5.1.4 of NFPA 58, 1998 Edition?

    17. On installations with liquid strainers, are they installed onthe suction of your pump or meter according to 3-2.15.3

    and 2-5.5 of NFPA 58, 1998 Edition and capable of being

    cleaned?

    18. On installations with flexible connections on pumps,

    compressors or loading and unloading bulkheads, are they

    installed as specified by 2-4.6 of NFPA 58, 1998 Edition?

    19. Do you have either excess flow valves, backflow check

    valves or internal valves as specified by 2-3.3.3 and 3

    3.3.7 of NFPA 58, 1998 Edition?

    20. Do you have container appurtenance protection as

    specified in 2-3.7 of NFPA 58, 1998 Edition?

    21. Do you have manual valves and emergency shutoff valves

    as required by 2-4.5.4, 3-2.10.11, 3-3.3.7 and 3-3.3.8 of

    NFPA 58, 1998 Edition?

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    Human Factors Yes/No/NA Comments

    3. Are your operators whose job duties require the use of

    the above listed equipment understand the operating

    limits of the system in regards to:

    Capacity?

    Pressure?

    Temperature?

    Adverse Weather or Natural Conditions?

    4. Have your operators been trained in the correct response

    to conditions which exceed the operating limits of the

    system?

    5. Have your operators been trained in their duties for

    emergency conditions?

    Fire?

    LP Gas Release?

    Severe Weather or Natural Conditions?

    6. Are the written operating instructions available to the

    operators (see 68.52 of this model program)?

    7. Do the written operating instructions reflect current

    operation of the facility (see 68.52 of this model

    program)?

    8. Have major modifications to your propane storage facility

    taken place (see 68.48 of this model program)?

    9. Are contractors used at the facility?

    10. Are safe work practices such as lock/tag, hot work and

    line opening followed at the facility?

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    Human Factors Yes/No/NA Comments

    11. Is there a written emergency response plan (see Subpart E

    of this model program)?

    Is it current?

    Have your operators been trained?

    Do you provide emergency response equipment?

    Has it been checked?

    General Hazards Yes/No/NA Comments

    1. Does your propane storage facility have protection

    against tampering as specified in under 3-3.6 of NFPA58, 1998 Edition?

    2. Does your propane storage facility have lighting as

    specified in 3-3.7 of NFPA 58, 1998 Edition?

    3. Is the area around your containers and transfer piping free

    of all combustible material?

    4. Has a fire safety analysis been performed for your

    propane storage facility as suggested by 3-10.2.2 and 3

    10.2.3 of NFPA 58, 1998 Edition?

    5. Has your fire safety analysis been reviewed by your localfire authority?

    6. Has your facility been required by your local fire

    authority to provide special protection?

    Fixed Water Sprays/Monitor Nozzles?

    Insulating Coatings?

    Mounding/Burial?

    Other types?

    7. Has a federal, state or local agency or fire authority

    required:

    Local Gas Detection Monitors?

    Perimeter Gas Monitors and Public Alarms?

    This Hazard Review was Completed by: On (Date):

    The latest date by which all changes resulting from the process hazard review are expected

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    to be completed is . .

    Date

    OPERATING PROCEDURES REQUIREMENTS

    Procedure

    Requirement

    NPGA Certified Employee

    Training Program

    (CETP)

    NPGA Bulletin

    (1) Initial Startup: Distribution

    Systems

    Operations

    Preparing Propane Storage

    Containers for Installation.

    Distribution

    Systems

    Operations

    Identifying Procedures Used to

    Pressure Test and Leak Check

    New Propane Distribution

    Systems.

    (2) Normal Operations: Transfer Systems Identifying Propane Pumps andtheir Operation.

    Transfer Systems Identifying Parts and Devices

    Basic to Compressors.

    Plant Operations Filling Propane Storage

    Containers.

    Plant Operations Unloading a Propane

    Transport.

    Plant Operations Unloading a Propane Tank

    Car.

    Propane Delivery Filling Cargo Tanks on BulkDelivery Vehicles.

    (3) Temporary

    Operations:

    Plant Operations Removing Propane from

    Stationary ASME Tanks and

    DOT Cylinders.

    (4) Emergency Shutdown

    and Operation:

    200-89 How to Control LP-Gas

    Leaks & Fires

    202-81 What you should do in

    case of accidents

    involving LP-Gas

    202-93 Steps to Take in the Event

    of an Accident Involving

    Propane

    204-88 How to Handle LP-Gas

    Fires with Portable Fire

    Extinguisher

    206-91 Emergency Response

    Guidelines

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    Procedure

    Requirement

    NPGA Certified Employee

    Training Program

    (CETP)

    NPGA Bulletin

    207-94 Guidelines for Developing

    Plant Emergency

    Procedures

    211-91 LP-Gas Fire Control and

    HAZ MAT Training

    Guide

    (5) Normal(Manual)

    Shutdown:

    (6) Startup following a

    normal or emergency

    shutdown or a major

    change that requiresa hazard review: See

    item (1) above.

    (7) Consequences of

    deviations and steps

    required to correct or

    avoid deviations.

    (8) Equipment

    inspections.

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    MAINTENANCE TRAINING

    Module Certified Employee Training Program (CETP)

    Basic Principles Identifying the Proper Use of Personal Protective Equipment

    Basic Principles Identifying the Proper Use of Tools and Equipment

    Basic Principles Identifying by Sight Hand Tools Commonly Used by Service Technicians

    Basic Principles Identifying Pipe/Tube, Pipe/ Fittings, and Associated Tools

    Transfer Systems

    Operations

    Identifying Propane Pumps and Their Operation

    Transfer Systems

    Operations

    Identifying the Standards for Sizing, Installing and Inspecting Pump Protective

    Devices

    Transfer Systems

    Operations

    Troubleshooting Propane Pumps and Metered Delivery Systems

    Transfer Systems

    Operations

    Identifying Parts and Devices Basic to Compressors

    Transfer Systems

    Operations

    Maintaining and Troubleshooting Compressors

    Distribution Systems Identifying the Operating Characteristics of Propane Vapor Regulators and

    Metering Systems

    Distribution Systems Installing Propane Vapor Regulating and Metering Systems

    Distribution Systems Sizing Pipe for Use in Low Pressure Propane Distribution Systems

    Distribution Systems Identifying Steel/Wrought Iron Piping Materials and Installing Procedures

    Distribution Systems Identifying Tubing Materials and Installing Procedures

    Distribution Systems Identifying and Sizing Vaporizer Systems

    Distribution Systems Sizing Propane Liquid Piping Systems

    Distribution Systems Identifying Installing and Servicing Procedures for Vaporizer Systems

    Plant Operations Identifying the Operating Characteristics of Pressure Relief Valves

    Plant Operations Identifying and Installing Gauges in Propane Storage Containers

    Plant Operations Identifying the Operating Characteristics of Check Valves

    Plant Operations Identifying the Operating Characteristics of Service Valves

    Plant Operations Installing Valves in Propane

    Plant Operations Inspecting Servicing and Maintaining Container Valves

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    Module Certified Employee Training Program (CETP)

    Transfer Systems

    Operations

    Identifying the Operation and Maintenance of Withdrawal Valves

    Transfer Systems

    Operation

    Identifying the Operation and Maintenance of Bulkheads and Emergency Shutoff

    Valves (ESVs)

    Distribution Systems

    Operations

    Installing Propane Liquid Distribution and Vaporizer Systems

    Transfer Systems

    Operation

    Identifying the Operation and Maintenance of Hoses, Hose End Valves, and Hose

    Reels

    Distribution Systems

    Operations

    Identifying the Causes of Corrosion on Metal Surfaces

    Distribution Systems

    Operations

    Identifying Methods and Procedures Used to Protect Metal Structures from

    Corrosion

    Distribution Systems

    Operations

    Identifying Procedures Basic to Installing Anodes and Testing Cathodic Protection

    Systems

    Distribution Systems

    Operations

    Identifying Procedures Used to Pressure Test and Leak Check New Propane

    Distribution Systems

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    MAINTENANCE INSPECTION CHECKLIST AND TESTS FOR PROPANE STORAGE

    FACILITIES

    I. Construction Code Compliance Yes No and Comment

    a) Check manufacturers data plate. Is it securely attached

    and legible?

    For each fixed storage vessel?

    On installations with vaporizers, for each vaporizer?

    b) Are the data plate(s) free of corrosion?

    II. Conditions of Container(s) and Vaporizer(s) and Paint Yes No and Comment

    a) Are above-ground containers properly painted?

    Fixed storage tanks?

    On installations with vaporizers, the vaporizers?

    b) Are containers and vaporizers free of corrosion damage,

    dents, gouges, or other damage?

    III. Foundations Yes No and Comment

    a) Are foundations in good condition?

    b) Are footings free of settling which might cause

    misalignment or piping strain?

    c) Are containers and vaporizers free of corrosion at masonry

    contact area?

    d) Are saddle pads in good condition?

    IV. Container Connections Yes No and Comment

    a) Have excess flow and back flow check valves been recently

    checked for proper operation?

    V. Tank Fittings Yes No and Comment

    a) Are all ACME (or other type) connectors in good condition

    with good gaskets and are they plugged or capped? (See

    NPGA Bulletin #134 Care and Inspection of ACMEThreaded Hose Couplings.)

    b) Are all unused openings plugged or capped?

    c) Are all fittings and hoses leak free?

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    a) Check manufacturers data plate. Is it securely attached

    and legible?

    For each fixed storage vessel?

    On installations with vaporizers, for each vaporizer?

    b) Are the data plate(s) free of corrosion?

    d) Are there visible signs of exterior corrosion?

    XI. Valves (for Fixed Storage Tanks and Vaporizers) Yes No and Comments

    a) Are valves in good working order?

    b) Do seats shut off tightly?

    c) Is packing free of leaks?

    d) Are necessary valve handles available at the valve location?

    XII. Hydrostatic Relief Valves (for Fixed Storage Tanks and

    Vaporizers)

    Yes No and Comments

    a) Are the valves in good working order and not leaking?

    b) Are the valves fitted with protective caps?

    c) Are the valve discharges positioned to avoid impinging gas

    on the tank?

    XII. Transfer Areas Yes No and Comments

    a) Are hoses in good condition and free of deterioration, wear,

    and blisters? See NPGA Bulletin #114 Guide to Hose

    Inspection.

    b) Are hoses capped or plugged when not is use?

    c) Are hose couplings properly attached and fully seated on

    the hose?

    d) Are hose couplings worn or damaged?

    e) Are coupling gaskets in good condition?

    f) Are correct coupling wrenches available?

    g) Are excess flow valves operating correctly?

    h) Are the loading and unloading risers protected from traffic?

    I) Are chock blocks provided for rail cars?

    j) Have your fire extinguishers been tested and/or serviced?

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    a) Check manufacturers data plate. Is it securely attached

    and legible?

    For each fixed storage vessel?

    On installations with vaporizers, for each vaporizer?

    b) Are the data plate(s) free of corrosion?

    k) Is adequate transfer hose storage available?

    m) Are the written transfer instructions readily available?

    XIV. Pumps and Compressors Yes No and Comments

    a) Are the shafts free of leaks?

    b) Are pumps equipped with a spring loaded by-pass valve

    where required?

    c) Is the by-pass valve functioning properly?

    d) Are drive belts or couplings protected by suitable guards?

    e) Is the compressor crank case oil at the proper level?

    XV. Electrical Equipment Yes No and Comments

    a) Do all switches, etc. function properly?

    b) Are all housings properly assembled to maintain seal?

    Inspected By: Inspection Date:

    These procedures were last reviewed or inspected by: Date:

    Name (signature)

    Piece of Equipment Inspected: Most Recent

    Date: